9911796707
TMI Blog2025 (4) TMI 406X X X X Extracts X X X X X X X X Extracts X X X X ..... ER PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as 'the CIT(A)') dated 19.04.2023, for assessment year 2017-18. 2. The primary issue raised by the assessee in appeal is against the addition of Rs. 26,18,000/- u/s. 69A of the Income Tax Act,1961(her ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng bank account no. 30068688518 statement and also bank account statement of account no. 033201005126 with ICICI Bank Ltd. Referring to SBI bank statement, as a sample he pointed that on 21.10.2016 Rs. 1,00,004/- was transferred to Jitendra Pal, and on the same date, vide separate transaction of an equal amount was further transferred to Jitendra Pal by the assessee. He further referred to transac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ash deposits in bank account of the assessee during the period of demonetization. The assessee has explained source of cash deposits in his bank accounts i.e. the cash was deposited by his employer Jitendra Pal. The assessee further explained that the entire cash deposit in the bank account of the assessee was subsequently transferred to Jitendra Pal through banking channel. To substantiate his co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... increase the rate of tax from 30% to 60%. The Hon'ble Madras High Court in the case of Smile Microfinance Ltd. vs. ACIT in WP(MD)No. 2078 of 2020 dated 19.11.2024 has held that the revised rate of tax @60% would be effective only from 01.04.2017. Accordingly, prior to 01.04.2017 the rate of tax applicable would be 30%. Hence, for AY 2017-18 the rate of tax applicable would be prior to amendment. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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